Partner Code of Conduct

1. Purpose

CUGINE GROUP LTD (Company No. 17412330), incorporated in England and Wales, expects partners, suppliers, advisers and collaborators working with CUGINE and its operating businesses to conduct business lawfully, responsibly and with integrity. This Code sets the minimum standards we expect in every relationship.

2. Integrity and anti-corruption

Partners must not offer, request, give or accept bribes, kickbacks or improper advantages. Conflicts of interest must be disclosed promptly and accurately.

3. Legal and regulatory compliance

Partners must comply with applicable laws, licences, sanctions, anti-money-laundering requirements, competition rules and tax obligations in every relevant jurisdiction.

4. Human rights and working conditions

Partners must respect human rights, prohibit forced labour, child labour, harassment and discrimination, and provide safe and lawful working conditions.

5. Data, confidentiality and intellectual property

Confidential information and personal data must be protected and used only for authorised purposes. Intellectual-property rights must be respected.

6. Responsible communications

Partners must represent CUGINE, its portfolio and shared projects accurately. Public statements, logos and brand assets may be used only with appropriate permission.

7. Environmental responsibility

Partners should seek to reduce waste, use resources responsibly and consider environmental impact in their operations and delivery.

8. Reporting concerns

Concerns about misconduct should be raised promptly through legal@cuginegroup.com. Retaliation against a person who raises a genuine concern is not acceptable.

9. Consequences

Material or repeated breaches may lead to corrective action, suspension or termination of the relationship, subject to contractual rights and applicable law.